1. Personal Information
(a) “Personal Information” means information about an identifiable individual, including all data, whether true or not, about an individual who can be identified (i) from that data, or (ii) from that data and other information to which the organisation has or is likely to have access;
(b) “Data Protection Laws” means any applicable law relating to the protection, privacy and security, collection, use, disclosure and/or processing of sensitive or other personally identifiable information, including the Singapore Personal Data Protection Act 2012 (“PDPA“) (collectively, “Data Protection Laws“).
1.2 Examples of such Personal Information which you may provide us include (depending on the nature of your interaction with us):
(a) your name and address, image, age and gender, personal financial records, identification numbers including your National Registration Identification Card number, Social Insurance Number and personal references, to the extent permitted by applicable local laws, and any other information that you have provided to us or was collected by us from other sources, or in other forms of interaction with you; and
(b) information about your use of our Website, App and services, including cookies, information about your domain name and IP addresses.
1.3 For the avoidance of doubt, in the event that Data Protection Laws permit the Cityneon Group to collect, use, disclose and/or process your Personal Information without your consent, such permission granted by the law shall continue to apply.
2. Collection of Personal Information
2.1 Generally, we collect your Personal Information in the following ways:
(a) Information you provide to us: Personal Information that you provide to us, such as when using the contact form on our Website or App, including your name, image, email address, and other contact details;
(b) Our correspondence: if you contact us, we will typically keep a record of that correspondence;
(c) Survey information: We may also ask you to complete surveys that we use for research purposes. In such circumstances we shall collect the information provided in the completed survey;
(d) Promotions: We may request Personal Information to administer your participation in contests, sweepstakes or other promotions that we organise;
(e) Marketing preference information: Details of your marketing preferences (e.g. communication preferences) and information relevant to selecting appropriate products and services to offer you;
(f) Website, App and communication usage: Details of your visits to the Websites and Apps and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your device, browser version and operating system, traffic data, location data, web logs, other communication data, and the resources that you access;
(g) CCTV and Events: When your images are captured by us via CCTV cameras while you are within our property and/or premises, or via photographs or videos taken by us or our representatives when you attend our events;
(h) Activities on Social Networking Sites (SNS): If you choose to participate (for example, by “liking” Cityneon’s profile on Facebook or Twitter, posting a message, or answering a poll), we will have access to the information you divulge which may include Personal Information; and
(i) Publicly Available Sources: From publicly available sources.
2.2 When you browse our Website or use our App, you generally do so anonymously but please see paragraph 10 below for information on cookies which we have implemented on our Website.
2.3 If you provide us with any Personal Information relating to a third party (e.g. information on your dependent, spouse, children and/or parents), by submitting such information to us, you represent and warrant to us that you have obtained the consent of such third party to you providing us with their Personal Information, and for the further collection, use, disclosure and/or processing by us of their Personal Information, for the purposes contemplated hereunder, and that such consents have not been withdrawn.
2.4 You shall ensure that all Personal Information submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and/or services which you have requested.
3. Purposes for the Collection, Use, Disclosure and/or Processing of Personal Information
3.1 In general, we collect, use, disclose and/or process your Personal Information for the following purposes:
(a) To provide and manage products and services you have requested. To administer our services, including to carry out our obligations arising from any agreements entered into between you and us, or to notify you about changes to our services and products, as well as to ensure that we have correct or up to date information about you (such as your current address or date of birth) and to better manage your relationship with us.
(b) To communicate with you regarding information, products and services that may be of interest. To provide you with updates and offers.
(c) To understand our customers and to develop and tailor our products and services. We may analyse the Personal Information we hold in order to better understand your usage patterns and preferences, as well as to better understand our business and develop our products and services;
(d) To inform you of changes. To notify you about changes to our services and products;
(e) To ensure Website or App content is relevant. To ensure that content from our Websites or Apps is presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers;
(f) To reorganise or make changes to our business. In the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your Personal Information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer your Personal Information to that re-organised entity or third party after the sale or reorganisation for them to use for the same purposes as set out in this policy;
(g) In connection with legal or regulatory obligations. We may process your Personal Information to comply with our regulatory requirements or dialogue with regulators as applicable which may include disclosing your Personal Information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime;
(h) To conduct audits. To conduct audits, reviews and analysis of our internal processes, action planning and manage commercial risks; and/or
(i) For purposes which are reasonably related to the aforesaid.
3.2 Furthermore, and without prejudice to the generality of the foregoing, and where permitted under Data Protection Laws, we may also collect, use, disclose and/or process your Personal Information for any of the following purposes:
(a) to send you invitation(s) to form part of our consumer panel, testing product, interviews or research groups (unless you unsubscribe from receiving marketing material from Cityneon Group);
(b) to contact you regarding current or new Services offered by the Cityneon Group or current or new events, products and/or services offered by other third parties (unless you unsubscribe from receiving marketing material from Cityneon Group);
(c) to inform you of new features, special offers and sales promotions offered by the Cityneon Group or other third parties (unless you unsubscribe from receiving marketing material from Cityneon Group); and/or
(d) to match Personal Information with other data collected for other purposes and from other sources (including third parties) in connection with the customisation, provision or offering of products, services, marketing or promotions, whether by the Cityneon Group or other third parties.
3.3 If you have provided us with your telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your telephone number(s), then from time to time, we may contact you using such telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services.
3.4 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use, disclose and/or process your Personal Information. If so, we will collect, use, disclose and/or process your Personal Information for these additional purposes as well, unless we have specifically notified you otherwise.
3.5 You may withdraw your consent by contacting us using the contact details set out at paragraph 12.
4. Disclosure of Personal Information
(a) amongst the Cityneon Group and its subsidiaries, affiliates and related corporations (including their respective staff);
(b) contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those which provide administrative or other services to us such as delivery service providers, insurance providers, payment processing service providers, web analytics tool providers, mailing houses, telecommunication companies, information technology companies and data centres;
(c) vendors or third party service providers and our marketing and business partners in connection with any Services and/or marketing promotions;
(d) our corporate clients;
(e) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale);
(f) external banks, credit card companies, other financial institutions and their respective service providers;
(g) our professional advisers such as consultants, auditors and lawyers;
(h) relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or
(i) any other party to whom you authorise us to disclose your Personal Information to.
4.2 We may share information about you in aggregate or anonymised form, for example, information regarding business product related reviews, with the abovementioned entities or parties (e.g. our business partners).
5. Deemed consent
In addition to the matters set forth above, subject to and in accordance with applicable law, you shall be deemed to have consented to Cityneon Group collecting, using, disclosing and sharing amongst ourselves your Personal Information, and disclosing such Personal Information to Cityneon Group’s authorised service providers and relevant third parties:
(a) where in response to a request for your Personal Information in connection with identified purposes, you voluntarily provide such Personal Information to Cityneon Group for such purpose(s);
(c) where we have brought to your attention our intention to collect, use or disclose your personal data for identified purposes, and you have not taken any action to opt out within the period specified in our notices. For this purpose, you agree that we may provide you such notices via the Websites, Apps or via other forms of communication (e.g. SMS or email) based on the contact particulars that we may have of you in our records from time to time.
6. Other Bases for Handling or Processing Your Personal Information
(b) for improving our products, services, processes or business, understanding customer preferences and personalising experiences and recommendations, based on your Personal Information records with any Cityneon Group companies (regardless whether you are an existing or prospective customer of any Cityneon Group companies).
7. Securing your Personal Information
7.1 We use commercially reasonably physical, electronic and procedural safeguards to protect against unauthorized use, access, modification, destruction, disclosure, loss or theft of your Personal Information in our custody or control in accordance with applicable law.
7.2 We have agreements and controls in place with third party service providers requiring that any information we provide to them must be safeguarded and used only for the purpose of providing the service we have requested the company to perform.
8. Security over the Internet
No data transmission over the Internet, r Website or App can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Personal Information in accordance with applicable law.
9. Retention of your Personal Information
Our retention periods for personal data are based on business needs and legal requirements. We retain your Personal Information for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purposes.
10.2 Web beacons (also known as pixel tags and clear GIFs) involve graphics that are not apparent to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our Website or platforms. Web beacons are usually used in conjunction with cookies and primarily used for statistical analysis purposes. This technology can also be used for tracking traffic patterns on our Website and platforms, as well as finding out if an e-mail has been received and opened and to see if there has been any response.
10.3 We may employ cookies and other technologies as follows:
(a) tracking information such as the number of visitors and their frequency of use, profiles of visitors and their preferred sites;
(b) making our Website and platforms easier to use. For example, cookies may be used to help speed up your future interactions with our Website and platforms;
(c) to better tailor our products and services to your interests and needs. For example, cookies information may be identified and disclosed to our vendors and business partners to generate consumer insights;
(d) collating information on a user’s search and browsing history;
(e) when you interact with us on our Website and platforms, we may automatically receive and record information on our server logs from your browser. We may collect for the purposes of analysis, statistical and site-related information including, without limitation, information relating to how a visitor arrived at the Website or platform, the browser used by a visitor, the device and operating system a visitor is using, a visitor’s IP address, and a visitor’s click stream information and time stamp (which may include for example, information about which pages they have viewed, the time the pages were accessed and the time spent per web page);
(f) using such information to understand how people use our Website and platforms, and to help us improve their structure and contents;
(g) using cookies that are necessary in order to enable our Website and platforms to operate, for example, cookies that enable you to log onto secure parts of our Website and platforms; and/or
(h) personalising the Website and platform for you, including delivering advertisements which may be of particular interest to you and using cookie related information to allow us to understand the effectiveness of our advertisements.
10.4 Some cookies we use are from third party companies to provide us with web analytics and intelligence about our Website and platforms. These companies collect information about your interaction with our Website and platforms. We use such information to compile statistics about visitors who interact with the Website, platforms and other Cityneon Group’s online content, to gauge the effectiveness of our communications, and to provide more pertinent information to our visitors.
11. Third-Party Sites
12. Contacting Us – Withdrawal of Consent, Access and Correction of Your Personal Information
12.1 We will use reasonable endeavours to ensure that your Personal Information is accurate. In order to assist us with this, you should notify us of any changes to the Personal Information that you have provided to us by contacting us as set out in the “Contacting Us” section below.
12.2 If you:
(c) would like to obtain access and make correction to your Personal Information records, please contact us as follows:
Cityneon Holdings Pte Ltd
Data Protection Officer
25 Tai Seng Avenue #06-01
We would also appreciate if you mention at the subject header of any mail and/or email that your mail and/or email is a PDPA-related request in order to allow us to pass your mail and/or email in an efficient manner to our Data Protection Officer
12.3 Please note that if your Personal Information has been provided to us by a third party (e.g. your employer), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to the Cityneon Group on your behalf.
12.4 If you withdraw your consent to any or all use of your Personal Information, depending on the nature of your request, we may not be in a position to continue to provide our Services to you, or administer any contractual relationship in place, which in turn may also result in the termination of any agreements with us, and your being in breach of your contractual obligations or undertakings. Our legal rights and remedies in such event are expressly reserved.
14. Governing Law
Date of last revision: 30 August 2022